PAN Rules 2026 Explained: New PAN Quoting Limits, Form 97, Property Transactions, Cash Deposit Rules & Reporting Changes Under Income Tax Rules 2026

PAN compliance in India has moved into a more data-driven phase from 1 April 2026. The Income-tax Act, 2025 and Income-tax Rules, 2026 do not merely rename old forms - they reorganise how banks, registrars, insurers, forex dealers, hotels, event businesses and other reporting persons collect and report financial information.

The biggest practical change is the arrival of Form No. 97 in place of the old Form 60 mechanism for specified no-PAN cases. But one point needs special care: for property transactions, there are two different limits that people often mix up. Rule 159 uses a ₹20 lakh threshold for PAN quoting in immovable property transactions, while Rule 237 uses a ₹45 lakh threshold for SFT reporting. Also, a person without PAN entering a property transaction above ₹45 lakh is expected to apply for PAN.

This guide explains the new PAN Rules 2026 in plain language, with examples for taxpayers, property buyers, banks, insurance companies, businesses and professionals.

PAN Rules 2026 infographic showing new PAN limits, Form 97 replacement, property transaction rules, revised cash deposit thresholds and PAN compliance checklist

Why PAN Rules Matter in 2026

PAN, or Permanent Account Number, is not only a tax filing identity. It is the connecting thread between your bank accounts, property transactions, investments, insurance payments, cash movement and many high-value financial activities.

The Income Tax Department uses PAN-linked information to identify whether the financial activity reported by institutions is reasonably aligned with the income disclosed by the taxpayer. A high-value transaction is not automatically a tax problem. The issue starts when the source of funds, accounting treatment or return reporting does not match the transaction trail.

DN & CO. practical view: PAN compliance should not be treated as paperwork. It is part of your financial evidence trail. If the transaction is genuine, documentation is your best protection.

Quick Summary of PAN Rules 2026

Form 97 Form No. 97 is the new declaration route for specified no-PAN cases under Rule 159. It replaces the old Form 60 mechanism under the new Act framework.
Property PAN quoting starts at the ₹20 lakh Rule 159 threshold, while SFT reporting for registrars applies at the ₹45 lakh Rule 237 threshold.
Cash Trail Cash deposits and withdrawals are now watched through annual aggregate thresholds, not only through one-off transactions.
Transaction Important PAN / Reporting Limit Who Should Be Careful
Purchase, sale, gift or JDA of immovable property PAN quoting under Rule 159 if amount or stamp value exceeds ₹20 lakh; SFT reporting under Rule 237 at ₹45 lakh or more Property buyers, sellers, donors, developers, registrars and sub-registrars
Cash deposits in bank or post office accounts Rule 159 covers cash deposits aggregating to ₹10 lakh or more in a financial year; Rule 237 reporting applies at ₹10 lakh with PAN and ₹5 lakh without PAN for non-current accounts Small businesses, traders, rural account holders and cash-heavy taxpayers
Cash withdrawals from bank or post office Rule 159 covers cash withdrawals aggregating to ₹10 lakh or more in a financial year; current account cash deposits or withdrawals have a separate ₹50 lakh SFT threshold under Rule 237 Contractors, traders, firms and businesses using regular cash withdrawals
Foreign currency purchase or forex card / traveller instrument Rule 237 reporting threshold: ₹10 lakh or more with PAN; ₹5 lakh or more without PAN Travellers, students, forex dealers and outward payment planners
Hotel, restaurant, convention centre, banquet hall or event management bill Rule 159 covers cash payment exceeding ₹1 lakh against bill or bills at any one time Wedding families, event organisers, corporates and hospitality businesses
Insurance premium Rule 159 covers account-based relationship with insurer where premium exceeds ₹50,000 in a financial year; Rule 237 reporting applies at ₹5 lakh with PAN and ₹2.5 lakh without PAN Policyholders, insurers, ULIP investors and high-premium life insurance buyers
Motor vehicle or motor cycle Rule 159 covers sale or purchase exceeding ₹5 lakh, including eligible motor cycles; tractor is excluded Car dealers, premium bike buyers and vehicle finance teams
Stamp paper purchase through Stock Holding Corporation of India Limited Rule 237 reporting threshold: ₹2 lakh with PAN; ₹1 lakh without PAN in one transaction Property lawyers, businesses, consultants and documentation teams

Form 97 Replaces Form 60

Under the old framework, a person who did not have PAN could furnish Form 60 for specified transactions. Under the Income-tax Act, 2025 and Income-tax Rules, 2026, the comparable declaration is now Form No. 97 for specified cases covered by Rule 159.

The Income Tax Department has clarified in its official forms guidance that persons who do not possess PAN may enter into specified Rule 159(2) transactions by filing Form No. 97, and that Form No. 97 replaces the earlier Form 60 mechanism under the new Act framework.

Important: Form 97 is not a casual bypass for PAN. The person receiving the document must verify whether PAN or Form 97 details are correctly recorded and linked with information reported to the income-tax authority where applicable.

For a detailed DN & CO. explainer on similar form changes, you may also read our guide on new Income Tax Forms 2026 and old vs new form mapping.

Property Transactions: ₹20 Lakh vs ₹45 Lakh Explained

This is the most misunderstood part of the new PAN framework. Many summaries say, "PAN applies above ₹45 lakh property." That is incomplete.

Common mistake: Treating ₹45 lakh as the only property limit. In reality, Rule 159 and Rule 237 work differently.

1. Rule 159: PAN Quoting Threshold Is ₹20 Lakh

Rule 159 requires PAN to be quoted in documents for purchase, sale, gift or joint development agreement of immovable property where the transaction amount exceeds ₹20 lakh or the stamp valuation exceeds ₹20 lakh.

This means property transfers are not limited to ordinary sale deeds. Gift deeds and Joint Development Agreements are also expressly covered.

2. Rule 237: SFT Reporting Threshold Is ₹45 Lakh

Rule 237 deals with furnishing of statement of financial transaction. Under this rule, registrars and sub-registrars report purchase, sale, gift or JDA of immovable property where the amount is ₹45 lakh or more, or the stamp duty value is ₹45 lakh or more.

3. No-PAN Property Cases Above ₹45 Lakh

Rule 159(3) further provides that a person, not being a company or firm, who does not have PAN and enters into a property transaction above the ₹45 lakh threshold must apply for PAN.

Property PAN compliance = Check ₹20 lakh Rule 159 first + Check ₹45 lakh Rule 237 reporting separately

Practical Example

Suppose Mr. A gifts a flat to his daughter. The registered gift deed shows a stamp duty value of ₹52 lakh. In this case, the transaction is covered because gift of immovable property is specifically included. PAN compliance will be important, and the transaction may fall within SFT reporting because the stamp duty value crosses ₹45 lakh.

If you are also dealing with an NRI property transaction, read our related DN & CO. guide on Non-Resident TDS, DTAA and NRI property compliance from FY 2026-27.

Cash Deposits and Cash Withdrawals

The new framework gives relief in some routine banking situations but increases the importance of annual tracking. Instead of looking only at one isolated deposit, taxpayers should track the aggregate value of cash deposits and withdrawals during the financial year.

Cash Deposits

Rule 159 covers cash deposits aggregating to ₹10 lakh or more in a financial year in one or more accounts of a person with a bank, co-operative bank or post office.

Rule 237 separately provides SFT reporting for cash deposits in accounts other than current accounts and time deposits where cash deposits in a financial year aggregate to ₹10 lakh or more for a person having PAN, and ₹5 lakh or more for a person not having PAN.

Cash Withdrawals

Rule 159 also covers cash withdrawals aggregating to ₹10 lakh or more in a financial year in one or more accounts of a person. For current accounts, Rule 237 has a separate SFT threshold for cash deposits or cash withdrawals aggregating to ₹50 lakh or more in a financial year.

Practical caution: PAN compliance and income taxability are different things. A cash deposit may be reportable, but it is not taxable merely because it was deposited. The question is whether the source is properly explained through books, invoices, withdrawals, agricultural records, capital receipts or other evidence.

For a broader checklist on banking limits, AIS and notice-risk areas, read our detailed guide on Bank Transaction Limits 2026 in India.

Forex, Insurance, Hotels and Event Payments

Foreign Exchange and Forex Cards

Rule 237 covers receipt from any person for sale of foreign currency, including credit to a foreign exchange card or expense in foreign currency through debit card, credit card, traveller's cheque, draft or other instrument.

The threshold is ₹10 lakh or more in a financial year for a person having PAN and ₹5 lakh or more for a person not having PAN. This matters for students going abroad, frequent travellers, forex card users and authorised dealers.

Insurance Premiums

Insurance is now more visible in the reporting framework. Rule 159 covers commencement of account-based relationship with an insurer where insurance premium exceeds ₹50,000 during a financial year. Rule 237 separately covers insurance premium receipts aggregating to ₹5 lakh or more with PAN and ₹2.5 lakh or more without PAN.

For example, if a person pays annual premiums of ₹6 lakh across high-value life insurance or investment-linked policies, the insurer may have reporting obligations under the rules.

Hotels, Banquet Halls and Event Managers

Rule 159 now specifically covers cash payments exceeding ₹1 lakh at any one time to a hotel, restaurant, convention centre, banquet hall or any person engaged in event management against bill or bills.

This is especially relevant for weddings, conferences, family functions and corporate events. A single cash-heavy event payment can create a PAN compliance requirement.

Vehicles, Stamp Paper and Pre-paid Instruments

Motor Vehicles and Premium Two-Wheelers

Rule 159 covers sale or purchase of a motor vehicle or vehicle requiring registration, excluding tractors, and also covers motor cycles as defined in the Motor Vehicles Act. The transaction threshold is amount exceeding ₹5 lakh.

So, a premium two-wheeler purchase above ₹5 lakh can attract PAN compliance. Agricultural tractors, however, are specifically excluded from this entry.

Stamp Paper Purchases

Rule 237 includes purchase of stamp paper through Stock Holding Corporation of India Limited. The reporting threshold is ₹2 lakh or more in one transaction for a person having PAN and ₹1 lakh or more for a person not having PAN.

RBI Regulated Pre-paid Instruments

Rule 237 also covers payments made in cash or otherwise for purchase of pre-paid instruments issued by RBI under the Payment and Settlement Systems Act, 2007, where the amount aggregates to ₹10 lakh or more during the financial year.

Why this matters: The law is now looking beyond only cash. Some reportable categories also cover payments made otherwise than cash, which is why digital records and KYC consistency are becoming more important.

What Businesses Should Update

Businesses should not wait for the year-end to review PAN records. The new rules affect day-to-day onboarding, billing, receipt, KYC and reporting systems.

  • Real estate businesses: Update documentation checklists for sale, gift and JDA transactions.
  • Banks and post offices: Track annual aggregate cash deposits, withdrawals and time deposits.
  • Insurance companies: Monitor premium receipts and account-based relationships above specified thresholds.
  • Hotels and event managers: Build controls for cash bills exceeding ₹1 lakh.
  • Vehicle dealers: Capture PAN correctly for vehicles and eligible motorcycles above ₹5 lakh.
  • Businesses liable to audit: Continue monitoring high-value cash receipts and goods or services transactions carefully.

For businesses managing TDS and new-law transition together, our TDS Rate Chart FY 2026-27 and GST and Income Tax Compliance Changes FY 2026-27 guides may be useful companion reads.

Compliance Tips for Taxpayers

  1. Do not confuse PAN quoting with SFT reporting. Both are connected, but the thresholds may differ.
  2. Keep PAN updated in bank, investment, insurance and property records. Small spelling or data mismatches can create avoidable follow-up.
  3. Track annual cash movement. The new rules focus heavily on annual aggregates.
  4. Preserve source documents. Keep sale deeds, gift deeds, bank statements, loan papers, capital account records, cash books and invoices.
  5. Do not use Form 97 casually. If PAN is required or must be applied for, using only a declaration may not solve the compliance issue.
  6. Reconcile AIS and books before filing returns. Reported transactions can appear later in taxpayer information systems.
What you should learn from these changes: The government is reducing routine friction in some smaller transactions while making high-value financial behaviour more visible through structured reporting.

Frequently Asked Questions

1. Is PAN compulsory for property transactions above ₹45 lakh?

Yes, practically PAN becomes very important above ₹45 lakh because Rule 159(3) requires a no-PAN person to apply for PAN in such property cases, and Rule 237 SFT reporting applies at ₹45 lakh or more. However, the PAN quoting threshold under Rule 159 for property starts earlier, at more than ₹20 lakh.

2. Has Form 60 been replaced?

Under the Income-tax Act, 2025 framework, Form No. 97 is the declaration form for specified no-PAN cases under Rule 159. The Income Tax Department's official guidance says Form 97 replaces the earlier Form 60 mechanism under the new Act.

3. Can Form 97 be used for all property transactions?

No. Form 97 is relevant only for specified no-PAN cases. For immovable property above the ₹45 lakh threshold, a person without PAN is required to apply for PAN. Therefore, Form 97 should not be treated as a universal substitute for PAN.

4. What is the new cash deposit threshold?

Rule 159 covers cash deposits aggregating to ₹10 lakh or more in a financial year. Rule 237 reporting for cash deposits in non-current accounts applies at ₹10 lakh or more for a person having PAN and ₹5 lakh or more for a person not having PAN.

5. Are cash withdrawals now covered?

Yes. Rule 159 covers cash withdrawals aggregating to ₹10 lakh or more in a financial year in one or more accounts of a person with specified banking or post office institutions.

6. Are gift deeds covered under property reporting?

Yes. Purchase, sale, gift and joint development agreement of immovable property are specifically covered under the new rules.

7. Is PAN required for buying a luxury bike?

Yes, if the covered motor cycle transaction exceeds ₹5 lakh, Rule 159 can apply. This is a notable expansion compared with how many people understood the old vehicle PAN rule.

8. Are tractors covered under the vehicle PAN rule?

No. Tractors are specifically excluded from the motor vehicle entry under Rule 159.

9. Do insurance premiums get reported?

High-value insurance premiums can be reportable. Rule 237 covers insurance premium receipts aggregating to ₹5 lakh or more for a person having PAN and ₹2.5 lakh or more for a person not having PAN.

10. Why did the government introduce these changes?

The policy direction is clear: reduce avoidable compliance friction for smaller routine transactions, but improve traceability for property, cash movement, forex, insurance and other high-value transactions.

Official References

Final Thoughts

The PAN Rules 2026 mark a shift from old-style form collection to more structured financial reporting. For taxpayers, the safest approach is simple: quote PAN wherever required, apply for PAN where the rule requires it, avoid casual cash handling in high-value transactions, and keep proper documents ready.

For businesses and professionals, this is the right time to update KYC checklists, billing software, property transaction documentation, insurance onboarding controls and annual transaction review processes. The rules are not designed to punish genuine taxpayers, but they do expect genuine taxpayers to leave a clear and consistent paper trail.

Disclaimer: This article is for educational purposes only and is based on the Income-tax Rules, 2026 and official Income Tax Department material reviewed on 27 May 2026. It should not be treated as legal or professional advice for a specific transaction. Please consult your Chartered Accountant or tax advisor before acting on high-value property, banking, forex, insurance or business transactions.
Chartered Accountant & Partner, DN & CO. CA Devendra Rojasara Surat, Gujarat, India | Income Tax, GST, TDS and audit guidance

Devendra Rojasara is a Chartered Accountant (CA Final – January 2026) and the Partner of DN & CO., a tax and accounting firm based in Surat, Gujarat. He has hands-on experience in Income Tax, GST, TDS/TCS compliance, tax audits, and account finalization gained through his articleship. On this blog, he shares practical, updated guidance to help Indian taxpayers, business owners, and finance professionals navigate tax laws with confidence.

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